Review of Regulation 206/2012 and 626/2011 Air conditioners and comfort fans - Task 1 report - ECEEE
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Review of Regulation 206/2012 and 626/2011 Air conditioners and comfort fans Task 1 report Final version Date: May 2018 1
Viegand Maagøe A/S Nr. Farimagsgade 37 1364 Copenhagen K Denmark viegandmaagoe.dk Prepared by: Viegand Maagøe and ARMINES Study team: Baijia Huang, Jan Viegand, Peter Martin Skov Hansen, Philippe Riviere, Florian Dittmann Quality manager: Jan Viegand Website design and management: Viegand Maagøe A/S Contract manager: Viegand Maagøe A/S Prepared for: European Commission DG ENER C.3 Office: DM24 04/048 B-1049 Brussels, Belgium Contact person: Veerle Beelaerts E-mail: veerle.beelaerts@ec.europa.eu Project website: www.eco-airconditioners.eu Specific contract no.: No. ENER/C3/FV 2016-537/03/FWC 2015-619 LOT2/01/SI2.749247 Implements Framework Contract: № ENER/C3/2015-619 LOT 2 This study was ordered and paid for by the European Commission, Directorate-General for Energy. The information and views set out in this study are those of the author(s) and do not necessarily reflect the official opinion of the Commission. The Commission does not guarantee the accuracy of the data included in this study. Neither the Commission nor any person acting on the Commission’s behalf may be held responsible for the use which may be made of the information contained therein. This report has been prepared by the authors to the best of their ability and knowledge. The authors do not assume liability for any damage, material or immaterial, that may arise from the use of the report or the information contained therein. © European Union, May 2018. Reproduction is authorised provided the source is acknowledged. More information on the European Union is available on the internet (http://europa.eu). 2
Table of contents List of tables ......................................................................................................... 4 List of figures ........................................................................................................ 6 Abbreviations ........................................................................................................ 7 Introduction to the task reports ............................................................................... 8 1 Task 1...........................................................................................................10 1.1 Product scope ...........................................................................................10 1.1.1 Existing definitions and categories .........................................................10 1.1.2 Product scope alignment .......................................................................17 1.1.3 Assessment of extending product scope ..................................................20 1.1.4 Recommended product scope ................................................................24 1.2 Test standards (EU, Member State and third country level).............................26 1.2.1 Energy performance for primary functions ..............................................26 1.2.2 Energy performance for secondary functions of air conditioners .................53 1.2.3 Noise standards ...................................................................................53 1.2.4 Refrigerant standards ...........................................................................55 1.2.5 WEEE and RoHS standards ....................................................................57 1.2.6 Mandates issued by the EC to the European Standardization Organizations .58 1.3 Legislation ................................................................................................60 1.3.1 EU legislation ......................................................................................60 1.3.2 Member State legislation ......................................................................77 1.3.3 Third country legislation .......................................................................79 1.4 Conclusions and recommendations ..............................................................88 3
List of tables Table 1. Products in scope, categorisation and definitions. .........................................11 Table 2. Prodcom categories covering products relevant for this study. .......................17 Table 3: Synthesis of the different air conditioner and cooling generator types and of their inclusion in existing Ecodesign and labelling regulations .....................................21 Table 4: Synthesis of the different fan types and of their inclusion in existing Ecodesign and labelling regulations ........................................................................................23 Table 5: Recommended product scope. ...................................................................25 Table 6: Air to air, testing conditions in the heating mode (EN14511-2:2013) ..............27 Table 7: Air to air, testing conditions in the cooling mode (EN14511-2:2013) ..............28 Table 8: Air to air, testing conditions in cooling mode (EN14511-3:2013) ....................30 Table 9: bin number j, outdoor temperature Tj in oC and number of hours per bin hj corresponding to the reference cooling season .........................................................33 Table 10: Part load conditions for reference SEER and reference SEERon: air to air units ..........................................................................................................................34 Table 11: bin number j, outdoor temperature Tj in °C and number of hours per bin hj corresponding to the reference heating seasons ―warmer, ―average, ―colder ............37 Table 12: The weighting coefficients by temperature bins ..........................................42 Table 13: Hours to be used to compute the TCSPF ....................................................43 Table 14: Distribution of temperature occurrences over the season ............................44 Table 15: Baseline test results ...............................................................................48 Table 16: Investigation test results, impact of air infiltration on unit performance ........48 Table 17: Investigation test results, impact of varying outdoor conditions of air infiltration on unit performance .............................................................................................49 Table 18: Investigation test results, impact of insulating ducts on unit performance (comparison with calorimeter test results, outdoor conditions temperatures 35/24 (dry bulb/wet bulb) .....................................................................................................49 Table 19: USA portable air conditioners final test method: standard test conditions ......49 Table 20: USA portable air conditioners: hours to compute energy consumption ..........52 Table 21: Regulation 206/2012 - minimum efficiency requirements ............................61 Table 22: Regulation 206/2012- The requirements for maximum power consumption in off-mode and standby ...........................................................................................61 Table 23: Requirements for maximum sound power level of air conditioners ................62 Table 24: Information requirements for air conditioners, except double duct and single duct air conditioners .............................................................................................62 Table 25: Information requirements for single duct and double duct air conditioners. ....64 Table 26:Information requirements for comfort fans .................................................65 Table 27: Regulation 626/2011 – Energy efficiency classes for air conditioners, except double ducts and single .........................................................................................67 Table 28: Regulation 626/2011 – Energy efficiency classes for double ducts and single ducts are .............................................................................................................68 Table 29: Impact of maximum uncertainty level according to EN14825:2016 standard on SEER and SCOP declared values .............................................................................70 Table 30: Prohibition of high GWP refrigerants .........................................................76 Table 31: Quotas for hydrofluorocarbons .................................................................76 Table 32: Ecolabel minimum requirements of the coefficient of performance (COP).......77 Table 33: Ecolabel minimum requirements of the energy efficiency ratio (EER) ............77 Table 34: Blue Angel requirements for the sound power level at rated capacity ............78 4
Table 35: MEPS: MINIMUM EER FOR AIR COOLED CONDENSER AIRCONDITIONERS (from AS/NZS 3823.2‐2009) .........................................................................................79 Table 36: Japan full load MEPS for air conditioners ...................................................81 Table 37: Japan APF Top Runner efficiency target - Air conditioners for home use - Non- duct and wall-hung type: Fiscal year 2010 ...............................................................82 Table 38: Japan APF Top Runner efficiency target - Air conditioners for home use - Others: Fiscal year 2012 .......................................................................................82 Table 39: Japan APF Top Runner efficiency target - Air conditioners for business use: Fiscal year 2015 ...................................................................................................82 Table 40 Minimum requirement and energy label allowable limits ...............................84 Table 41 APF requirement and energy label allowable limits for variable speed air conditioners according to MEPS GB 21455 -2013 ......................................................84 Table 42: SEER requirement and energy label allowable limits for variable speed air conditioners according to MEPS GB 21455 – 2008 and GB 21455 – 2013 .....................85 Table 43: Minimum performance thresholds based on CEER (USA) .............................86 Table 44: Seasonal Energy Efficiency Ratio and Heating Seasonal Performance minimum requirements for central air conditioners .................................................................87 Table 45: Energy Efficiency Ratio for central air conditioners in selected states ............87 Table 46: Minimum requirements for average off mode electrical of central air conditioners .........................................................................................................87 Table 47: Energy Conservation Standards for Portable Air Conditioners .......................88 Table 48: Recommended product scope. .................................................................89 5
List of figures Figure 1: Division of the different products for space heating into sub-categories. ........18 Figure 2: Schematic overview of the SCOPon calculation points (for a on-off cycling air to water unit, in EN14825:2016, Annex E, p 74) ..........................................................36 Figure 3: Impact of using lock-in mode versus compensation method on the energy efficiency of an inverter air conditioning unit ............................................................40 Figure 4: Example of an energy label for a reversible air conditioner ...........................67 Figure 5: Proposed label designs for single duct air conditioners in Australia in 2009. Text on the label: "This product has a cooling function when ducted to the outside, but during hot weather hot air is drawn into the building to replace the exhausted hot air. Over time this may result in an increase in indoor temperatures in other parts of the building. Please ask your retailer about alternatives." ............................................................80 Figure 6 China Energy Label for air conditioners 2004 version that is out of use (left) and the currently in use 2010 version (right) .................................................................83 Figure 7 China Energy Label for variable speed air conditioners according to MEPS GB 21455 -2013 ........................................................................................................84 6
Abbreviations Cdc, The cycling degradation coefficient for air Cdh conditioners in cooling (heating) mode Coefficient of Performance for air conditioners COP in heating mode CDD Cooling Degree Day Energy Efficiency Ratio for air conditioners in EER cooling mode EPS External Static Pressure for air conditioners GNI Gross national income GWP Global warming potential The number of hours the unit is considered to HTO work in thermostat off mode for air conditioners The number of hours the unit is considered to HSB work in standby mode for air conditioners The number of hours the unit is considered to HCK work in crankcase heater mode for air conditioners The number of hours the unit is considered to HOFF work in off mode for air conditioners The electricity consumption during thermostat PTO off mode for air conditioners The electricity consumption during standby PSB mode for air conditioners The electricity consumption during crankcase PCK heater mode for air conditioners POFF The electricity consumption during off mode. The reference annual cooling demand for air QCE conditioners in cooling mode The reference annual heating demand for air QHE conditioners in heating mode SHR Sensible Heat Ratio for air conditioners Seasonal Energy Efficiency Ratio for air SEER conditioners, cooling mode Seasonal Coefficient of Performance for air SCOP conditioners, heating mode VRF Variable Refrigerant Flow 7
Introduction to the task reports This is the introduction to the interim report of the preparatory study on the Review of Regulation 206/2012 and 626/2011 for air conditioners and comfort fans. The interim report has been split into five tasks, following the structure of the MEErP methodology. Each task report has been uploaded individually in the project’s website. These task reports present the technical basis to define future ecodesign and energy labelling requirements based on the existing Regulation (EU) 206/2012 and 626/2011. The task reports start with the definition of the scope for this review study (i.e. task 1), which assesses the current scope of the existing regulation in light of recent developments with relevant legislation, standardisation and voluntary agreements in the EU and abroad. Furthermore, assessing the possibility of merging implementing measures that cover the similar groups of products or extend the scope to include new product groups. The assessment results in a refined scope for this review study. Following it is task 2, which updates the annual sales and stock of the products in scope according to recent and future market trends and estimates future stocks. Furthermore, it provides an update on the current development of low-GWP alternatives and sound pressure level. Next task is task 3, which presents a detailed overview of use patterns of products in scope according to consumer use and technological developments. It also provides an analysis of other aspects that affect the energy consumption during the use of these products, such as component technologies. Furthermore, it also touches on aspects that are important for material and resource efficiency such as repair and maintenance, and it gives an overview of what happens to these products at their end of life. Task 4 presents an analysis of current average technologies at product and component level, and it identifies the Best Available Technologies both at product and component level. An overview of the technical specifications as well as their overall energy consumption is provided when data is available. Finally, the chapter discusses possible design options to improve the resource efficiency. Simplified tasks 5 & 6 report presents the base cases, which will be later used to define the current and future impact of the current air condition regulation if no action is taken. The report shows the base cases energy consumption at product category level and their life cycle costs. It also provides a high-level overview of the life cycle global warming potential of air conditioners and comfort fans giving an idea of the contribution of each life cycle stage to the overall environmental impact. Finally, it presents some identified design options which will be used to define reviewed ecodesign and energy labelling requirements. Task 7 report presents the policy options for an amended ecodesign regulation on air conditioners and comfort fans. The options have been developed based on the work throughout this review study, dialogue with stakeholders and with the European Commission. The report presents an overview of the barriers and opportunities for the reviewed energy efficiency policy options, and the rationale for the new material/refrigerant efficiency policy options. This report will be the basis to calculate the estimated energy and material savings potentials by implementing these policy options, in comparison to no action (i.e. Business as Usual – BAU). 8
The task reports follow the MEErP methodology, with some adaptations which suit the study goals. 9
1 Task 1 Task 1 follows the MEErP methodology and includes the following: • Product scope: Identification and assessment of relevant categories based on the existing ecodesign regulation, standardisation and measurement method activities and other relevant schemes and activities outside EU. Defining preliminary product scope, definitions and categorisations. • Test standards: EU, Member State and third country level. • Legislation: EU, Member State and third country level. 1.1 Product scope The current scope of Commission Regulation (EU) No 206/2012 covers electric mains- operated air conditioners with a rated capacity of ≤ 12 kW for cooling, or heating if the product has no cooling function, and comfort fans with an electric fan power input ≤ 125W. The current scope of Commission Delegated Regulation (EU) No 626/2011 covers electric mains-operated air conditioners with a rated capacity of ≤ 12 kW for cooling, or heating if the product has no cooling function. The definition of air conditioners is presented and discussed in the next sub-section. 1.1.1 Existing definitions and categories 1.1.1.1 Existing definitions and categories in Ecodesign Regulation (EU) No 206/2012 Commission Regulation (EU) No 206/2012 establishes ecodesign requirements for air conditioners and comfort fans. The product definitions employed in the regulation are listed below. Products and components that are within the scope of the Regulation are defined as: Air conditioner means a device capable of cooling or heating, or both, indoor air, using a vapour compression cycle driven by an electric compressor, including air conditioners that provide additional functionalities such as dehumidification, air-purification, ventilation or supplemental air-heating by means of electric resistance heating, as well as appliances that may use water (either condensate water that is formed on the evaporator side or externally added water) for evaporation on the condenser, provided that the device is also able to function without the use of additional water, using air only. Double duct air conditioner means an air conditioner in which, during cooling or heating, the condenser (or evaporator) intake air is introduced from the outdoor environment to the unit by a duct and rejected to the outdoor environment by a second duct, and which is placed wholly inside the space to be conditioned, near a wall. Single duct air conditioner means an air conditioner in which, during cooling or heating, the condenser (or evaporator) intake air is introduced from the space containing the unit and discharged outside this space. Comfort fan means an appliance primarily designed for creating air movement around or on part of a human body for personal cooling comfort, including comfort fans that can perform additional functionalities such as lighting. 10
Capacity limitation: the scope for air conditioners is limited to "air conditioners with a rated capacity of ≤ 12 kW for cooling, or heating if the product has no cooling function". Table 1 below describes what are the common products within the scope of regulation 206/2012 as interpreted by the study team. Table 1. Products in scope, categorisation and definitions. Product Product category Definition group Split (Non-ducted fixed split-packaged unit) A split-packaged unit is defined as a factory assembly of components of a refrigeration system fixed on two or more mountings to form a matched unit. This type of appliance comprises two packages (one indoor and one outdoor unit) connected only by the pipe that transfers the refrigerant. The indoor unit includes the evaporator Air conditioners - cooling only and reversible (respectively condenser in heating mode) and a fan, while the outdoor unit has a fan, compressor and a condenser (respectively evaporator in heating mode). Fixed non-ducted indoor units can be mounted high on a wall, floor- mounted or as ‘cassette’, ceiling- suspended, built-in horizontal or built-in vertical. Mobile Split (Non-ducted split packaged Indoor unit(s) can be also be non- unit with mobile indoor unit) ducted and mobile. Mobile split units are often categorised at points of sales as mobile or portable air conditioners. Opposed to fixed split, the compressor is located in the indoor unit, while the outdoor unit only contains the condenser heat exchanger and fan. The outdoor unit for a mobile split can be either fixed or mobile. 11
Product Product category Definition group Ducted split packaged unit Indoor unit(s) for split can also be ducted. Ducted indoor units can deliver cool air to several rooms or to several spots within a single room. Multi-split packaged units Multi-split packaged units comprise several interior units (up to 4) connected to one exterior unit. These units are similar to split interior and exterior units. Indoor units can be ducted or non- ducted. Multi Variable Refrigerant Flow (VRF) units1 This type of product is similar to multi-split packaged units, except instead of having one refrigerant connection between each indoor unit and the outdoor unit, the refrigerant is distributed in the building via a single connection to the outdoor unit. This product may allow to have heating and cooling in different zones of the building and heat recovery between zones, these options are not available for multi-split package air conditioners. These have been mostly non- residential products, but recently some manufacturers offer smaller systems ≤ 12 kW. 1 Images source: http://york-vrf.com/ 12
Product Product category Definition group Single-packaged unit, through the wall Single-packaged units, commonly known as ‘window’ or ‘through- the-wall’ air conditioners (respectively they are called “room air conditioners” and “package terminal air conditioners” in the USA), are strictly defined as a factory assembly of components of a refrigeration system fixed on a common mounting to form a single unit. This type of equipment comprises a single package, one side of which is in contact with the outside air heat release outside, while the other side provides direct cooling to the air inside. The two sides of the appliance are separated by a dividing wall, which is insulated to reduce heat transfer between the two sides. This type of air conditioners has relatively low sales in the EU but is more common in the USA. Single duct mobile air conditioner Single-packaged mobile units, commonly known as ‘mobile’ or 'portable' air conditioners comprise a single package, one side of which extracts indoor air to cool the condenser and releases it outdoor, while the other side provides direct cooling to the air indoor. The two sides of the appliance are separated by a dividing wall, which is insulated to reduce heat transfer between the two sides. 13
Product Product category Definition group Double duct air conditioner (through the wall A double duct air conditioner is an installation) evolution of the single duct. There are two main types. The first type is exactly similar to a single duct but a Indoor Outdoor second hole at the condenser enables to take the condenser air from outside thus reducing outside air infiltration inside the room to be cooled. The second type is similar, but of a more permanent installation through the wall and in that case, the two ducts may be concentric. Comfort fans Comfort fans primary function is to increase air speed in such a manner the end user may feel more comfortable. Since air speed must not be increased too much to get acceptable comfort conditions and that comfort is likely to be increased if the air stream attains a larger part of the body, the function of the unit Comfort fans would then be “to move air inside a room” and the performance parameter to be kept is the air flow rate supplied by the fan. Comforts fans can be e.g. desk fans, floor standing fans, wall mounted fans, ceiling fans, tower fans, box fans, etc. The floor units typically have a high fan velocity and they are moving on the vertical axe, while the ceiling mounted unit has a lower fan velocity. Comments on the definitions: Air conditioners can reject heat to different outdoor fluids (outdoor air, ventilation exhaust air, water/brine). Cooling can also be supplied to recycled air or to outdoor air (case of ventilation exhaust heat pumps / air conditioners). This is not clearly defined in the present regulation. The definitions and scope of different ecodesign regulations should make sure all air conditioner / air to air heat pump types are covered. This is discussed in more details in part 1.1.3. 14
1.1.1.2 Existing definitions and categories in Ecodesign Regulation(EU) No 2016/2281 Commission Regulation (EU) No 2016/2281 is not under the current review, however the Regulation establishes definitions of various heat pumps, air conditioners and comfort chillers. These definitions are useful for understanding the differences between air conditioners and heat pumps covered by the different EU regulations, especially in relation to part 1.1.2 and 1.1.3, where the scope alignment and possible extension for the different types of air conditioners and heat pumps are discussed. Heat pump means an air heating product: A. of which the outdoor side heat exchanger (evaporator) extracts heat from ambient air, ventilation exhaust air, water, or ground heat sources; B. which has a heat generator that uses a vapour compression cycle or a sorption cycle; C. of which the indoor side heat exchanger (condenser) releases this heat to an air- based heating system; D. which may be equipped with a supplementary heater; E. which may operate in reverse in which case it functions as an air conditioner; And the following types of heat pumps are defined as: Air-to-air heat pump means a heat pump which has a heat generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (evaporator) allows heat transfer from ambient air and the indoor side condenser delivers the heat to the indoor air. Water/brine-to-air heat pump means a heat pump which has a heat generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (evaporator) allows heat transfer from water or brine Rooftop heat pump means an air-to-air heat pump, driven by an electric compressor, of which the evaporator, compressor and condenser are integrated into a single package. Sorption cycle heat pump means a heat pump which has a heat generator that uses a sorption cycle relying on external combustion of fuels and/or other type of supply of heat. Multi-split heat pump means a heat pump incorporating more than one indoor units, one or more refrigerating circuit, one or more compressors and one or more outdoor units, where the indoor units may or may not be individually controlled. Air conditioner is defined differently by Regulation (EU) No 2016/2281 than from Regulation (EU) No 206/2012: Air conditioner means a cooling product that provides space cooling and: A. of which the indoor side heat exchanger (evaporator) extracts heat from an air- based cooling system (heat source) B. which has a cold generator that uses a vapour compression cycle or a sorption cycle. C. of which the outdoor side heat exchanger (condenser) releases this heat to ambient air, water or ground heat sink(s) and which may or may not include heat transfer that is based on evaporation of externally added water. D. may operate in reverse in which case it functions as a heat pump; 15
Air-to-air air conditioner means an air conditioner which has a cold generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (condenser) allows heat transfer to air. Water/brine-to-air air conditioner means an air conditioner which has a cold generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (condenser) allows heat transfer to water or brine. Rooftop air conditioner means an air-to-air air conditioner, driven by an electric compressor, of which the evaporator, compressor and condenser are integrated into a single package. Multi-split air conditioner means an air conditioner incorporating more than one indoor units, one or more refrigeration circuits, one or more compressors and one or more outdoor units, where the indoor units may or may not be individually controlled. Sorption cycle air conditioner means an air conditioner which has a cold generator that uses a sorption cycle relying on external combustion of fuels and/or supply of heat. Air-to-water comfort chiller means a comfort chiller that has a cold generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (condenser) allows heat transfer to air, including heat transfer that is based on evaporation into this air of externally added water, provided that the device is also able to function without the use of additional water, using air only. Water/brine-to-water comfort chiller means a comfort chiller that has a cold generator that uses a vapour compression cycle driven by an electric motor or internal combustion engine and whereby the outdoor side heat exchanger (condenser) allows heat transfer to water or brine, excluding heat transfer that is based on evaporation of externally added water. Sorption cycle comfort chiller means a comfort chiller which has a cold generator that uses a sorption cycle relying on external combustion of fuels and/or supply of heat. Fan coil unit means a device that provides forced circulation of indoor air, for the purpose of one or more of heating, cooling, dehumidification and filtering of indoor air, for the thermal comfort of human beings, but which does not include the source of heating or cooling nor an outdoor side heat exchanger. The device may be equipped with minimal ductwork to guide the intake and exit of air, including conditioned air. The product may be designed to be built in or may have an enclosure allowing it be placed in the space to be conditioned. It may include a Joule effect heat generator designed to be used as back-up heater only. Air heating product means a device that: A. incorporates or provides heat to an air-based heating system; B. is equipped with one or more heat generators; and C. may include an air-based heating system for supplying heated air directly into the heated space by means of an air-moving device. A heat generator designed for an air heating product and an air heating product housing designed to be equipped with such a heat generator shall, together, be considered as an air heating product. 16
Cooling product means a device that: A. incorporates, or provides chilled air or water to, an air-based cooling system or water-based cooling system; and B. is equipped with one or more cold generator(s). A cold generator designed for use in a cooling product and a cooling product housing designed to be equipped with such a cold generator shall, together, be considered as a cooling product. 1.1.1.3 Prodcom (Eurostat) categories There are a number of PRODCOM codes that relate to air conditioners and associated products that may be within scope of any potential future update to the ecodesign Regulation on air conditioners. The PRODCOM categories which are covering products relevant for this study are listed in the table below. Table 2. Prodcom categories covering products relevant for this study. PRODCOM code PRODCOM Nomenclature Air conditioners 28.25.12.20 Window or wall air conditioning systems, self- contained or split-systems 28.25.12.50 Air conditioning machines with refrigeration unit (excluding those used in motor vehicles, self- contained or split-systems machines) 28.25.30.10 Parts for air conditioning machines (including condensers, absorbers, evaporators and generators) Comfort fans 27.51.15.30 Table, floor, wall, window, ceiling or roof fans, with a self-contained electric motor of an output
central heating or local (non-central) heating products, hydronic systems or dry systems products and cooling and ventilation. Local space heaters have the heat generator in the same room as the room that needs heating such as single duct air conditioners. Split/multisplit, double duct and multi variable refrigerant flow units are examples of central space heating units. As the illustration below shows are multiple products somehow related to the products within the scope of EU 206/2012. Heating Cooling Ventilation Solid fuels Electricity, gaseous fuels and liquid fuels (+hydronic) Local space heating products Dry Local 2015/1185 2015/1188 Space Air conditioners ≤ 12 kW 206/2012 Dry Central air heating products and cooling products Central Ventilation units 1253/2014 2016/2281 Central heating boilers 813/2013 Domestic Water Solid fuel Hydronic central heating boilers Central heating boilers 2015/1189 814/2013 Figure 1: Division of the different products for space heating into sub-categories.3 The following regulations are closely connected to the EU regulation No 206/2012 (in the borders of the scope): Regulation (EU) No 2015/1188, Regulation (EU) No 2015/1185, Regulation (EU) No 2016/2281 and Regulation (EU) No 1253/2014. Their scope is described below and in general aligns well with the scope of Regulation No 206/2012: Commission Regulation (EU) No 2015/1188 with regard to ecodesign requirements for local space heaters. Local space heaters are products that emit heat by direct heat transfer possibly in combination with heat transfer to a fluid. They are situated within the indoor space (rooms of houses or buildings, workshops, offices, warehouses, garages, hospitals, etc.) which they heat and in some cases they can in addition deliver heat to other spaces. The local space heaters under this Regulation are electric, gaseous or liquid fuel local space heaters. Outdoor heating products (e.g. terrace) are not within the scope. Air conditioners are also provided with heating functions but are though not within the scope due to scope exemption a) in the regulation. This Regulation includes domestic local space heaters with a nominal heat output of 50 kW or less and commercial local space heaters with a nominal heat output of the product or of a single segment of 120 kW or less. 3 http://www.eceee.org/static/media/uploads/site-2/ecodesign/products/lot-20-local-room-heating- products/bio-eup-lot20-task-1-final-report.pdf 18
The regulation does not apply to: a) local space heaters using a vapour compression cycle or sorption cycle for the generation of heat driven by electric compressors or fuel; b) local space heaters specified for purposes other than indoor space heating to reach and maintain a certain thermal comfort of human beings by means of heat convection or heat radiation; c) local space heaters that are specified for outdoor use only; d) local space heaters of which the direct heat output is less than 6 % of the combined direct and indirect heat output at nominal heat output; e) air heating products; f) sauna stoves; g) slave heaters. Commission Regulation (EU) No 2015/1185 with regard to ecodesign requirements for solid fuel local space heaters. Solid fuel space heaters are also local space heaters but are fired by solid fuels with a nominal heat output of 50 kW or less. Products within this scope are e.g. stoves and fireplaces and will not further be described here. Commission Regulation (EU) No 2016/2281 with regard to ecodesign requirements for air heating products, cooling products, high temperature process chillers and fan coil units. See definitions of the products covered by this Regulation in Section 1.1.1.2. This regulation exempts the products that are already covered by an ecodesign regulation, air conditioners and comfort fans within the scope of Regulation (EU) No 206/2012 are clearly out of the scope by the exemption item b), see below. The regulation of air heating products includes: a) air heating products with a rated heating capacity not exceeding 1 MW; b) cooling products and high temperature process chillers with a rated cooling capacity not exceeding 2 MW; c) fan coil units. The regulation has the following exemptions: a) products covered by Commission Regulation (EU) 2015/1188 with regard to ecodesign requirements for local space heaters; b) products covered by Commission Regulation (EU) No 206/2012 with regard to ecodesign requirements for air conditioners and comfort fans; c) products covered by Commission Regulation (EU) No 813/2013 with regard to ecodesign requirements for space heaters and combination heaters; d) products covered by Commission Regulation (EU) 2015/1095 with regard to ecodesign requirements for professional refrigerated storage cabinets, blast cabinets, condensing units and process chillers; e) comfort chillers with leaving chilled water temperatures of less than + 2 °C and high temperature process chillers with leaving chilled water temperatures of less than + 2 °C or more than + 12 °C; f) products designed for using predominantly biomass fuels; g) products using solid fuels; h) products that supply heat or cold in combination with electric power (‘cogeneration’) by means of a fuel combustion or conversion process; 19
i) products included in installations covered by Directive 2010/75/EU of the European Parliament and of the Council on industrial emissions; j) high temperature process chillers exclusively using evaporative condensing; k) custom-made products assembled on site, made on a one-off basis; l) high temperature process chillers in which refrigeration is effected by an absorption process that uses heat as the energy source; and m) air heating and/or cooling products of which the primary function is the purpose of producing or storing perishable materials at specified temperatures by commercial, institutional or industrial facilities and of which space heating and/or space cooling is a secondary function and for which the energy efficiency of the space heating and/ or space cooling function is dependent on that of the primary function. Commission Regulation (EU) 1253/2014 with regard to ecodesign requirements for ventilation units. This Regulation applies to ventilation units and establishes ecodesign requirements for their placing on the market or putting into service. Some ventilation units are equipped with a regenerative heat exchanger which means that a rotary heat exchanger incorporating a rotating wheel for transferring thermal energy from one air stream to another air stream. These types of products have a different function/purpose and are therefore not further described. In this regulation, reference is made to ventilation exhaust heat pumps for air heating purpose because of possible additional pressure losses, but ventilation exhaust air heating heat pumps and air cooling air conditioners are not in the scope of this regulation. Commission Regulation (EU) 327/2011 with regard to ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW. The products that falls under the scope of this regulation are not considered as a local space heater, though it is assessed in relation to comfort fans. The scope includes fans between 125 W and 500 kW, which aligns well with the scope of No 206/2012 for comfort fans ≤125 W. Regarding fans included in air conditioners with cooling power below 12 kW, there is a limited overlap with Regulation (EU) No 206/2012; it regards parts of the fans in ducted outdoor and indoor units, for larger static pressure difference and cooling capacity ranges (and thus air flows). Commission Regulation (EC) No 640/2009 with regard to ecodesign requirements for electric motors. and its amendment Commission Regulation (EU) No 4/2014. The current scope includes electric three-phase AC motors with output in the range 0.75-375 kW. With the current scope, there is no overlapping of motors used for comfort fans ≤125 W. All fan motors covered by Regulation (EU) 206/2012 have unitary power well below 0.75 kW and motors of compressors are not included in Commission Regulation (EC) No 640/2009 because they are hermetic motors incorporated in the compressor shell (hermetic non accessible). 1.1.3 Assessment of extending product scope This assessment focuses on products that are not included in any regulation and whether they should be included in the scope of this study. This assessment is made to assure alignment of the different regulations and to avoid any loopholes. Air Conditioners Air conditioners – Air conditioners are covered by Regulation (EU) No 206/2012 and 626/2011 if their cooling capacity is lower than or equal to 12 kW. Table 3 proposes a 20
synthesis of the different air conditioner and cooling generator types and of their inclusion in existing Ecodesign and labelling regulations. Table 3: Synthesis of the different air conditioner and cooling generator types and of their inclusion in existing Ecodesign and labelling regulations Product in scope Outdoor Indoor Capacity Ecodesign Labelling Usual product names side side threshold Regulation regulation Split, multi-split, window, Outdoor Recycled ≤ 12 kW through-the-wall, double 206/2012 626/2011 air air duct air conditioners Exhaust Recycled Single duct air ≤ 12 kW 206/2012 626/2011 air air conditioners Other relevant products Outdoor Indoor Capacity Ecodesign Labelling Usual product names side side threshold Regulation regulation Outdoor Recycled Split, multi-split, VRF, > 12 kW 2281/2016 None air air Rooftop air conditioners Water/ Recycled Water cooled air None 2281/2016 None brine air conditioners / heat pumps Ventilation exhaust air-to- Exhaust Outdoor air heat pumps and air None or ≤ 12 kW None air air conditioners (possibly 206/2012? reversible) Ventilation exhaust air-to- Exhaust Outdoor air heat pumps and air > 12 kW 2281/2016 None air air conditioners (possibly reversible) Air cooled chillers (cooling Air Water None 2281/2016 None only) Water/ Water cooled chillers Water None 2281/2016 None Brine (cooling only) ≤ 400 kW Air-to-water reversible (Ecodesign) Air Water chillers (heating function 813/2013 811/ 2013 / ≤ 70 kW only) (Label) ≤ 400 kW Water/brine-to-water Water/ (Ecodesign) Water reversible chillers (heating 813/2013 811/ 2013 Brine / ≤ 70 kW function only) (Label) Cooling/heating electric Outdoor Recycled vapor compression cycle None None None air air generators in air handling units (except rooftops) There are several product groups considered for scope extension of the regulation of air conditioners: Air conditioners > 12 kW are not within the scope of regulation No 206/2012. This was a potential loophole until the adoption of regulation (EU) No 2016/2281 with regard to ecodesign requirements for air heating products, cooling products, high temperature process chillers and fan coil units. This regulation covers all air conditioners above 12 kW and up to a rated heating capacity not exceeding 1 MW. 21
Water/brine-to-air air conditioners and heat pumps, which were not covered in
Regulation (EU) No 206/2012, are now covered by Regulation (EU) No 2016/2281: 'heat
generator' definition includes 'ambient air, ventilation exhaust air, water or ground heat
source(s)';'cold generator' definition specifies that heat extracted can be 'transferred to a
heat sink, such as ambient air, water or ground'. Ecodesign requirements regarding
water/brine-to-air air conditioners are information requirements defined in Annex II / 5 /
a / 4 of the Regulation (EU) No 2016/2281. Ecodesign requirements regarding water/brine-
to-air heat pumps are covered by information requirement in Annex II / 5 / a / 6 of
Regulation (EU) No 2016/2281.
Ventilation exhaust air-to-air heat pumps and air conditioners ≤ 12 kW are not
explicitly in the scope of regulation No 206/2012, nor are they clearly excluded, as the
type of indoor air used in the definition of air conditioners is unspecified ("a device capable
of cooling or heating, or both, indoor air"). These products with rated capacity of 12 kW
and above are quoted in regulation No 2016/2281 in the definition of 'heat pump'
Information requirements in regulation No 2016/2281 apply to them, although there is not
yet any part load conditions for these products to rate SEER and SCOP performances;
residential exhaust air-to-air heat pumps often have cooling / heating capacity ≤ 12 kW,
these are not currently included other regulations. It is advised to include these products
in the scope of Regulation (EU) No 206/2012 and 626/2011 when their thermal power is
below or equal to12 kW and to specify SEER and SCOP rating conditions. This also implies
better specification of which air is used indoor and outdoor for air conditioners and heat
pumps in Regulation (EU) No 206/2012. Test conditions for temperature and load to enable
calculation of SEER / SCOP are proposed in Annex 1 to this report.
Ventilation exhaust air-to-air heat pump and air conditioners > 12 kW appears to
be covered in Regulation (EU) No 2016/2281, 'ventilation exhaust air' is included in the
'heat generator' definition as a possible heat source; 'cold generator' definition specifies
that heat extracted can be 'transferred to a heat sink, such as ambient air, water or
ground', although it does not target explicitly 'ventilation exhaust air', it does not exclude
it. Standard rating conditions are given for these products in Regulation Annex III table
16. Information requirements table for both air-to-air air conditioners (Annex II table 11)
and air-to-air heat pumps (Annex II table 14) could be used. However, it should be noticed
that there is not yet any specific part load conditions defined for exhaust-air-to-outdoor-
air heat pump and air conditioners in EN14825:2016 nor in Regulation (EU) No 2016/2281.
Air or water cooled chillers (cooling only) are a possible air conditioner competitor in
residential or service premises. However, these are covered by regulation (EU) No
2016/2281.
Air-to-water reversible chillers are a possible air conditioner competitor in residential
or service premises. Regulation (EU) No 2016/2281 covers in general chillers, however it
should be noted that Commission Regulation (EU) No 813/2013 only covers the chiller
heating function. Thus, it is recommended also to include the cooling as the secondary
function of air-to-water reversible chillers when revising the Regulation (EU) No813/2013.
Water/brine-to-water reversible chillers are a possible air conditioner competitor in
residential or service premises. Regulation (EU) No 2016/2281 covers in general chillers,
however it should be noted that Commission Regulation (EU) No 813/2013 only cover the
chiller heating function only. Thus, it is recommended to include the cooling as the
22secondary function of water / brine-to-water reversible chillers when revising the Regulation (EU) No 813/2013. Cooling generators in air handling units (except rooftops) are not sold separately (as rooftop) but sold as a component of a specific air handling unit to pre-cool / pre-heat fresh air. According information available to the study team, these are not included in any EU Ecodesign or Labelling regulation. As a component of air handling units, these products were considered in ENTR Lot 6 study for air-conditioning and ventilation systems, but they were excluded from product scope because of low sales volumes. If cooling generators in air handling units should be included in any regulation, it should then be in regulations (EU) No 2016/2281 or in (EU) No 2014/1253. Secondary functions of air conditioners Air conditioners now commonly propose several functions in addition to heating and cooling. This includes air purifying, dehumidification and air movement (only the indoor fan is on). These additional functions are mentioned in Regulation (EU) No 206/2012 definition for air conditioners. However, room air conditioning products with other primary functions than space cooling/heating and air movement creation were excluded from the scope of preparatory study for air conditioners based on their low market sales and consequent low EU energy consumption. This regards in particular dehumidifiers and air purifiers. There was no reliable data showing these markets became significant enough to justify ecodesign measures, however it should be noted that these are growing markets. The preparatory study to establish the Ecodesign Working Plan 2015-20174 reported a lack of data for EU- 27, and an estimated annual primary energy consumption of dehumidifiers of 0.25 TWh, much greater consumption found for humidifiers of 23.6 TWh, especially steam humidifiers. The dehumidification capability, measured by the sensible- heat ratio (SHR), is drastically reduced when operating in cooling mode, according to EU test laboratories. It means that to dehumidify, end-users would need to use the separate dehumidification mode of air conditioners or to buy an additional equipment for dehumidifying in the cooling season. However, there is presently no standardized operating conditions to establish the performance of the dehumidification function of air conditioners. Comfort fans Comfort fans are covered by Regulation (EU) No 206/2012 and 626/2011 if their fan power input is lower than 125 W. Table 4 proposes a synthesis of the different fan types and of their inclusion in existing Ecodesign and labelling regulations. Table 4: Synthesis of the different fan types and of their inclusion in existing Ecodesign and labelling regulations Capacity threshold Usual product names Ecodesign Regulation Labelling regulation < 125 W Comfort fans 206/2012 626/2011 Capacity threshold Usual product names Ecodesign Regulation Labelling regulation > 125 W Fans, ventilation units 327/2011 None nominal heat output of < 50 kW Residential fan heaters 2015/1188 None 4 https://www.vdma.org/documents/266687/344832/Ecodesign+WP3_Draft_Task_3_report_20140616_1500.pdf /d7f57d0c-3158-4194-aa89-d376894d7307 23
There are several product groups considered for scope extension of comfort fans however the following assessment shows that none of the product groups requires modification of the scope of the Regulation (EU) No 206/2012 and 626/2011. The product groups considered are: Comfort fans with ≥ 125 W input power are not within the scope of the regulation No 206/2012. Instead these products are included in the regulation (EU) No 327/2011 with regard to ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW. The current assessment shows that there is no loophole for comfort fans with an input power of 125 W or above, and not necessary to extend the scope of No 206/2012. Residential fan heaters are not within the scope of the regulation No 206/2012 though part of them are able to provide the same service as comfort fans when heating is turned off; comfort fans are defined in Regulation No 206/2012 as ' appliance[s] primarily designed for creating air movement around or on part of a human body for personal cooling comfort', whereas the primary function of fan heaters is likely to be heating. Residential fan heaters are included in the regulation (EU) No 2015/1188 for local space heaters and are specified as a portable local room heater in the explanatory notes 5.Hence their primary function is already covered in Regulation (EU) No 2015/1188. With much higher energy consumption for heating as compared to the comfort fan function only, ecodesign should stay focused on the primary function. However, as they are able to compete with comfort fans, it would have an added value for end-users to have comparable information for the secondary function as is required for comfort fans. Thus, it is recommended to include information requirement on the "air movement" function of residential fan heaters in Regulation (EU) No 2015/1188 (similar to the information requirement for comfort fans in Regulation 206/2012). Evaporative coolers such as “misting fans” are not within the scope of Regulation No 206/2012, as the main principle for cooling is the evaporation of water, not air movement created by a fan. 1.1.4 Recommended product scope In conclusion, the scope of ecodesign regulations of different air cooling and heating product are well aligned, however there are two concerns. First of all, there is a possibility that ventilation exhaust air-to-air heat pumps and air conditioners ≤ 12 kW are not clearly covered by any regulation. They are not especially excluded from Regulation No 206/2012, hence it is recommended to include ventilation exhaust air-to-air heat pumps and air conditioners with heating or cooling capacity ≤ 12 kW in the revised scope. The draft definitions of exhaust air-to-air heat pumps and air conditioners are: • ‘Ventilation exhaust air to outdoor air heat pump” means a heat pump that extracts heat from the exhaust air of a building to supply it to the ventilation supply air for the thermal comfort of human beings by a compression cycle or a sorption cycle. The ventilation outdoor air passes through the condenser of the heat pump before entering the building. The exhaust air passes through the evaporator of the heat 5 http://edit.eceee.org/ecodesign/products/solid_fuel_small_combustion_installations/LRHS- 20120716ExplanatoryNotesFINAL.PDF 24
pump before being rejected outdoors. The unit can also be equipped with a heat recovery heat exchanger. • ‘Ventilation exhaust air to outdoor air conditioner” means an air conditioner that extracts heat from the ventilation inlet air of a building to supply it to the ventilation exhaust air for the thermal comfort of human beings by a compression cycle or a sorption cycle. The ventilation outdoor air passes through the evaporator of the air conditioner before entering the building. The exhaust air passes through the condenser of the air conditioner before being rejected outdoors. The unit can also be equipped with a heat recovery heat exchanger. The definition of a heat pump and air-to-air heat pump will also be added to the regulation. The definitions will be adapted from Regulation (EU) No 2016/2281 and are described above in section 1.1.1.2. Secondly, an additional function of residential fan heaters, currently covered by Regulation (EU) No 2015/1188, could be “creating air movement around or on part of a human body for personal cooling comfort”. This means it could be a competitor for comfort fans, information requirements on the “air movement” function of residential fan heaters could give end-users valuable comparable information. It is recommended that during the revision of Regulation (EU) No 2015/1188, similar information requirements for comfort fans are proposed for residential fan heaters targeting this secondary function. However, these are not proposed to be included in Regulation No 206/2012. Regarding cooling and heating, the regulation (EU) No 2012/206 did not include non- electric energy sources. In fact, there is presently no product using gas or other energy sources besides electricity for air conditioners. Extending the scope of Regulation (EU) No 206/2012 to non-electric energy sources would make it difficult for manufacturers to design products using non-electric energy sources, as they may not be able to reach the efficiency limit, at the same time it may also hinder innovation for air conditioners using renewable energy sources, such as biogas. Consequently, it is advised to keep non-electric energy sources outside of the scope. The exemptions to the product scope are still as follows: a. appliances that use non-electric energy sources; b. air conditioners of which the condenser side or evaporator side, or both, do not use air for heat transfer medium. The proposed product scope for Regulation 206/2012 is summarised in Table 5. Table 5: Recommended product scope. Categories Products included Scope limits Split, multi-split, window, Outdoor air / recycled air through-the-wall, double Cooling (heating) power duct, multi-split mini VRF ≤12 kW Exhaust air / recycled air Single duct Heat recovery ventilation Cooling (heating) power Exhaust air / outdoor air heat pump / air conditioner ≤12 kW Desk fans, floor standing fans, wall mounted fans, ceiling fans, tower fans, Comfort fans Electric fan power ≤ 125W box fans, etc. Portable fan heater with comfort fan mode. 25
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